HTML Document View

Full title: Certificate of No Objection Regarding Second Omnibus Objection (Substantive) of the Liquidation Trustee to Certain (I) Misclassified Claims and (II) No Liability Claims Pursuant to Section 502 of the Bankruptcy Code, Bankruptcy Rule 3007, and Local Rule 3007-1 (related document(s)[569]) Filed by Terry S. Park. (Attachments: # (1) Proposed Form of Order) (Jones, Scott)

Document posted on Oct 20, 2021 in the bankruptcy, 2 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

Case No. 20-12088 (MFW) ) MEA RemainCo Holdings, LLC, et al., )The undersigned hereby certifies that Terry S. Park, in his capacity as the Liquidation Trustee (the “Liquidation Trustee”) of the MEA RemainCo Holdings, LLC (f/k/a Energy Alloys Holdings, LLC) Liquidation Trust, has received no answer, objection or any other responsive pleading with respect to the Second Omnibus Objection (Substantive) of the Liquidation Trustee to Certain (I) Misclassified Claims and (II)No Liability Claims Pursuant to Section 502 of the Bankruptcy Code, Bankruptcy Rule 3007, and Local Rule 3007-1 ( the “Second Omnibus Objection”) filed by the Liquidation Trustee with the United States Bankruptcy Court for the District of Delaware (the “Court”) on October 6, 2021. The undersigned further certifies that no 1 The Debtors, together with the last four digits of each Debtor’s federal tax identification number, are MEA RemainCo Holdings, LLC (f/k/a Energy Alloys Holdings, LLC) (4144); MEA RemainCo, L.L.C. (f/k/a Energy Alloys, L.L.C.) (0377); MEA RemainCo Louisiana, LLC (f/k/a/ Energy Alloys Louisiana, LLC) (0623); MEA RemainCo Canada Holding, L.L.C. (f/k/a Energy Alloys Canada Holding, L.L.C.) (0382); MEA RemainCo Services, L.L.C. (f/k/a Energy Alloys Services, L.L.C.) (4284); MEA RemainCo Cayman Holding, L.L.C. (f/k/a Energy Alloys Cayman Holding, L.L.C.) (3484); MEA RemainCo Mexico Holding Co. – Majority, LLC (f/k/a Energy Alloys Mexico Holding Co. – Majority, LLC) (9165); MEA RemainCo Mexico Holding Co. – Minority, LLC (f/k/a Energy Alloys Mexico Holding Co. – Minority, LLC) (N/A).Email: scott.cousins@cousins-law.com scott.jones@cousins-law.com Counsel to Terry S. Park, solely in his capacity as the Liquidation Trustee of the MEA RemainCo Holdings, LLC (f/k/a Energy Alloys Holdings, LLC) Liquidation Trust

List of Tables

Document Contents

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE ) Chapter 11 In re: ) ) Case No. 20-12088 (MFW) ) MEA RemainCo Holdings, LLC, et al., ) (Jointly Administered) ) Debtors.1 ) ) Re: Docket No: 569 ) CERTIFICATE OF NO OBJECTION REGARDING SECOND OMNIBUS OBJECTION (SUBSTANTIVE) OF THE LIQUIDATION TRUSTEE TO CERTAIN (I) MISCLASSIFIED CLAIMS AND (II) NO LIABILITY CLAIMS PURSUANT TO SECTION 502 OF THE BANKRUPTCY CODE, BANKRUPTCY RULE 3007, AND LOCAL RULE 3007-1 The undersigned hereby certifies that Terry S. Park, in his capacity as the Liquidation Trustee (the “Liquidation Trustee”) of the MEA RemainCo Holdings, LLC (f/k/a Energy Alloys Holdings, LLC) Liquidation Trust, has received no answer, objection or any other responsive pleading with respect to the Second Omnibus Objection (Substantive) of the Liquidation Trustee to Certain (I) Misclassified Claims and (II) No Liability Claims Pursuant to Section 502 of the Bankruptcy Code, Bankruptcy Rule 3007, and Local Rule 3007-1 ( the “Second Omnibus Objection”) filed by the Liquidation Trustee with the United States Bankruptcy Court for the District of Delaware (the “Court”) on October 6, 2021. The undersigned further certifies that no 1 The Debtors, together with the last four digits of each Debtor’s federal tax identification number, are MEA RemainCo Holdings, LLC (f/k/a Energy Alloys Holdings, LLC) (4144); MEA RemainCo, L.L.C. (f/k/a Energy Alloys, L.L.C.) (0377); MEA RemainCo Louisiana, LLC (f/k/a/ Energy Alloys Louisiana, LLC) (0623); MEA RemainCo Canada Holding, L.L.C. (f/k/a Energy Alloys Canada Holding, L.L.C.) (0382); MEA RemainCo Services, L.L.C. (f/k/a Energy Alloys Services, L.L.C.) (4284); MEA RemainCo Cayman Holding, L.L.C. (f/k/a Energy Alloys Cayman Holding, L.L.C.) (3484); MEA RemainCo Mexico Holding Co. – Majority, LLC (f/k/a Energy Alloys Mexico Holding Co. – Majority, LLC) (9165); MEA RemainCo Mexico Holding Co. – Minority, LLC (f/k/a Energy Alloys Mexico Holding Co. – Minority, LLC) (N/A). The mailing address for the Debtors is 9450 Pinecroft Drive, P.O. Box 8819, The Woodlands, TX 77380.

1

answer, objection or other responsive pleading to the Second Omnibus Objection has appeared on the Court’s docket in the above-captioned chapter 11 case. Pursuant to the Notice of Objection filed with the Second Omnibus Objection, any objection or response to the Second Omnibus Objection was to be filed and served no later than October 20, 2021 at 4:00 p.m. (ET). WHEREFORE, the Liquidation Trustee respectfully requests that an order, substantially in the form attached hereto as Exhibit A, be entered at the earliest convenience of the Court. Dated: October 21, 2021 Wilmington, Delaware /s/ Scott D. Jones Scott D. Cousins (No. 3079) Scott D. Jones (No. 6672) COUSINS LAW LLC Brandywine Plaza West 1521 Concord Pike, Suite 301 Wilmington, Delaware 19803 Telephone: (302) 824-7081 Facsimile: (302) 295-0331 Email: scott.cousins@cousins-law.com scott.jones@cousins-law.com Counsel to Terry S. Park, solely in his capacity as the Liquidation Trustee of the MEA RemainCo Holdings, LLC (f/k/a Energy Alloys Holdings, LLC) Liquidation Trust

2